Polish JPK_VAT update: 1 April 2022 JPK_FA new format
The format for submissions of Polish VAT invoices, JPK_FA, has changed from 1 April 2022. JPK_FA(4) is an electronic format the tax authorities may request from taxpayers on demand for (for example) an audit. It captures any paper or electronic invoice related to VAT. It is one of the reports which form part of the wider Polish JPK_VAT format (see below), which is a form of Standard Audit File for Tax regime which replaced the traditional VAT return in October 2020 (see below).
1st January 2022 updates
Amendments from the start of 2022 should be noted for JPK V7M/K. These include:
- Following the 1 July EU e-commerce package, the marker for distance sales has been withdrawn and replaced with a new one, WSTO_EE, to cover intra-community sales of goods and digital services;
- Also following the e-commerce package, is a new marker, IED, for IOSS and OSS processed B2C sales.
- The split payments marker, MPP, is withdrawn
- The TP marker for state-related supplies has been withdrawn.
SAF-T replaced VAT returns 1 October 2020
Since October 2020, Poland became the first country to replace the summary VAT return with monthly / quarterly mandatory SAF-T transaction data submission. In Poland, Standard Audit Files for Tax are known as JPK_V7M/K – Jednolity Plik Kontrolny. The return is generally due by the 25th of the month following the reporting period.
Implementation of SAF-T in Poland
Poland first introduced the OECD’s standard accounting data schema, SAF-T, in July 2016 for large taxpayers. It has since been rolled out to all taxpayers, including non-residents. It is structured as follows:
- JPK_KR – Księgi Rachunkowe (account books)
- JPK_WB – Wyciągi bankowe (bank statements)
- JPK_MAG – Magazyn (stock warehouse/storage)
- JPK_VAT – Ewidencje zakupu i sprzedaży VAT (VAT sales and purchase ledgers)
- JPK_FA – Faktury VAT (VAT invoices)
- JPK_PKPIR – Podatkowa księga przychodów i rozchodów (Revenue and expense tax books)
- JPK_EWP – Ewidencja przychodów (Income records)
The JPK_VAT provides the tax authorities with monthly (JPK_V7M) or quarterly (JPK_V7K) details of most VAT invoices processed by a business. Quarterly filers must still complete monthly JPK_VAT filings; but the third-month filing of the quarter will continue a complete 3-month set of transactions.
There is a proposal for Polish e-invoicing to become mandatory from 2023/2. This will follow the Italian SdI e-invoice system, with preclearance of invoices. This Krajowy System e-Faktur – KseF – will go on voluntary trial at the end of 2021.
Reduced VAT rate updates and JPK_VAT
In July 2020, Poland recast the application of its VAT rates against various products to match international commodity code Combined Nomenlature (CN). The new matrix applies a single reduced VAT rate to an entire CN category to make company’s calculations simpler and more readily auditable. This was new CN (also termed GTU’s) was incorporated into the latest JPK_VAT
Standard Audit File for Tax SAF-T countries
|Country (click for details)||Date||Scope|
|13||Ukraine||Jan 2025||Phased 2025 to 2027 implementation|
|12||Bulgaria||Jan 2025||Phased introduction over two years|
|11||Denmark||2024?||Phased implementation from 2024|
|10||Romania||Jan 2022||Mandatory monthly filings initially large taxpayers (due Jan 2023)|
|9||EU OSS & IOSS||Jul 2021||On-demand for sellers, marketplaces or Intermediaries|
|8||Norway||2020||Replaced VAT return 2022|
|6||Lithuania||2019||On-demand; residents and non-residents above €30,000 sales threshold|
|5||Poland||2016||Mandatory, monthly replaced VAT return Oct 2020|
|1||Portugal||2009||Monthly for residents and non-residents (Jun 2022)|